Three years ago, you could attend an energy conference without hearing the words “large load.” Now, you can’t.

Issues related to large load are dominating the energy sphere as regulators, utilities, data center developers, and energy resource suppliers are all scrambling to navigate the need for significant new energy resources to meet this demand. The latest projections from Grid Strategies show that nationally, load is expected to grow by 5.7% per year over the next five years.

Meanwhile, the Wisconsin Public Service Commission (PSC) approved 11 projects totaling nearly 3,500 megawatts (MW) of new generation and storage to be sited in Wisconsin last year, and utility plans filed as part of the strategic energy assessment shows that this number could grow to over 7,250 MW of new generating capacity to be installed between 2026-30.^[1]

Pre-existing Pain Points

Pre-data center growth, our electricity generation and transmission system was already facing pain points associated with increased renewable resources, electrification, aging infrastructure, frequent extreme weather events, and the effects of decades of lacking regional and inter-regional transmission planning.

Ratepayers have taken notice as the price tag for all these grid upgrades adds up. Users and suppliers have been frustrated with the slow approval and connection processes. And regulators have anxiously watched as extreme weather events have tested the system’s resource adequacy.

Midwest Responses

Several of Wisconsin’s fellow Midwestern states have responded to these challenges by adopting new or increased opportunities for an iterative, long-term planning process known as integrated resource planning (IRP), coupled with streamlined permitting for resources that comprise approved plans:

Illinois (2025 SB 25): Requires the Illinois Commerce Commission (ICC) to complete a statewide IRP by November 2026.

Indiana (2025 HEA 1007/P. L. 217): Provides an expedited pathway for the permitting of generating resources that are included in an “expedited generation resource plan” or “EGP” if the resource was approved by the Indiana Utilities Regulatory Commission (IURC) in response to new large load demand.

Michigan (2023 Public Act 231): Requires the Michigan PSC to update IRP planning parameters and plan filing requirements and creates new considerations that the PSC must review in its evaluation of the plan, including varying load forecast projections in five-year increments.

Missouri (2025 SB 4): Requires investor-owned utilities to file an integrated resource plan subject to the Missouri PSC’s review and approval. If a new generating resource is included in an approved IRP, it is subject to an expedited review process for its CPCN.

Iowa: While Iowa state law does not require utilities to file IRP, settlements in other cases in the past few years have led both investor-owned utilities in Iowa to conduct resource planning. The Iowa Utilities Commission recently published guidelines for utilities to continue this practice on a voluntary basis.

Wisconsin is now an island surrounded by states that are engaging in a more wholistic approach to meeting demand growth with reliable and cost-effective solutions through IRPs that are, in most states, vetted and approved through a contested process.

Integrated Resource Planning Offers a 20-year Vision

While the process and requirements can vary state to state, generally IRP offers modeling of a utility’s load forecast, and an evaluation of what resources are needed to meet the utility’s load. Instead of evaluating generating resources (and in some cases, transmission and distribution resources) on a case-by-case basis, the IRP lays out the utility’s planned portfolio for up to the next 20 years. IRPs are then typically filed with the state utilities commission.

A key component to IRP in most states is stakeholder involvement^[2] Utilities in states that conduct IRP frequently host stakeholder workshops while they are developing their plans and seek feedback from stakeholders on modeling assumptions and inputs. This often results in a utility creating several IRP options and allows the utility’s constituents (and regulators) to weigh in on the factors that are most important to them in designing an electricity system that meets their needs.

Significantly, this stakeholder process can engender buy-in from parties that may otherwise oppose specific proposals, because they have a whole-picture understanding of what role each resource is intended to play in the system and how much it is expected to cost consumers over time.

Stakeholder participation can provide more than buy-in, however. Stakeholders in IRP may have access to technical analysis, data, and information that is outside the scope of what the utility typically considers. For example, stakeholders may bring perspectives on pilot projects or programs run in other jurisdictions, may propose novel approaches to cost savings, or may bring expertise on new and emerging technologies that can present innovative solutions for meeting demand.

Wisconsin: Siloed Projects

While it is true that Wisconsin utilities engage in resource planning on their own, the utility’s modeling and planning is not scrutinized through a contested process or approved by our Public Service Commission. Nor is it vetted through a stakeholder process.

Instead, the Wisconsin Public Service Commission reviews resources on a project-by-project basis in siloed proceedings, even when other applications for resources for the same utility are being considered at the same time.

Conclusion

Integrated resource planning is not a panacea, but serves as an important planning tool to solve for many of the challenges facing our electricity system.

With routine filings (typically every 2-5 years) that look out up to 20 years, IRP is typically an iterative process that accommodates needed adjustments and can offer streamlined determinations of cost-effectiveness and need for generator construction acquisition across the system.

Given the many current unknowns about how the current challenges facing the electricity sector will affect energy affordability, reliability, and sustainability, it is not surprising that states are looking to increase participation in utility planning efforts.

Could it be time for Wisconsin to do the same?

This article was originally published on the State Bar of Wisconsin’s Public Utilities Blog. Visit the State Bar sections or the Public Utilities Section webpages to learn more about the benefits of section membership.

Endnotes

[1] See “Strategic Energy Assessment 2024-2030,” Table 2-3, New Additions and Transfers of Utility-Owned or Leased Generation Capacity by Wisconsin Electric Providers 2024 through 2030, pp. 26-29, Public Service Commission of Wisconsin, November 2024. ↩

[2] See Bruce Biewald, et al., “Best Practices in Integrated Resource Planning: A guide for planners developing the electricity resource mix of the future,” Lawrence Berkeley National Lab, November 2024. ↩